Privacy policy

Last updated: [Effective date]

Draft for legal review

This policy was drafted from the Gulp product spec and has not been reviewed by a lawyer. It is not in effect yet. Highlighted text marks details we still need to fill in or confirm.

Who we are

Gulp is made by Astel ([Legal entity name], [Registered address]). We are responsible for the personal information described here. You can reach us at privacy@astelapps.com.

We wrote this policy to be read by people, so it tries to say plainly what we keep and why. The short version is that we collect what Gulp needs to work and to get better, we don't sell your data, and Gulp has no ads.

What we collect

Information you give us

Information collected as you use Gulp

[Review: drink logs are hydration records. Check whether they count as consumer health data under laws such as Washington's My Health My Data Act, or as health data under the GDPR, and whether that needs separate consent or a separate notice.]

How we use it

We don't sell your personal information, we don't share it for advertising, and Gulp shows no ads. [Review: legal bases for each use under the GDPR and UK GDPR, such as contract, legitimate interests and consent.]

What your squad sees

People in your squad see your display name, your mascot, today's counted gulps, whether you're on rhythm or soaked, your streak, and the squad's shared activity, such as who splashed whom and when the lake filled. They don't see your drink sizes, your volume or your settings. Anyone with your squad's invite link can ask to join it, so share it with people you know.

Who we share it with

We use a few trusted companies to run Gulp. They process data on our behalf and only for the jobs below.

ProviderWhat they do for Gulp
SupabaseDatabase, sign-in, real-time updates and server functions [region]
Apple and GoogleSign in, app distribution, payments and push delivery
ExpoPush notifications and app updates
RevenueCatPurchase and subscription records
PostHogProduct analytics and feature flags
SentryCrash and error reports
ResendAccount and transactional email
CloudflareThis website and invite links

We may also share information if the law requires it, to protect people's safety, or as part of a merger or sale of the business, in which case this policy would keep applying to your data. [Review: international transfers and the safeguards used, such as Standard Contractual Clauses.]

How long we keep it

We keep your information while your account is open. When you delete your account, we delete or anonymize it within [30] days, and it leaves our backups within [90] days. We keep purchase records for as long as tax and accounting rules require. Analytics and crash data are kept for [period].

Deleting your data

You can delete your account at any time in the app: go to Me and tap Delete account. That removes your account, drink log, mascot, drops, items and squad membership. Splashes and activity you were part of are removed or shown without your name. Subscriptions are billed by Apple or Google, so cancel them in your store account too. If you can't use the app, email privacy@astelapps.com from the address on your account and we'll delete it for you.

Your rights

Depending on where you live, you may have the right to see the data we hold about you, correct it, delete it, take a copy, object to or restrict some uses, and withdraw consent you've given. You can do most of this in the app, and for the rest, email privacy@astelapps.com. You can also complain to your local data protection authority. [Review: specific wording for the GDPR, UK GDPR, CCPA and CPRA, and other US state laws.]

Children

Open question, needs a decision and legal review

Gulp's onboarding currently offers a 3 to 12 age range. Collecting personal information from children under 13 requires verifiable parental consent under COPPA in the US, and similar consent rules apply to children in the EU and UK (GDPR, often called GDPR-K, and the UK Age Appropriate Design Code). Gulp's social features (squads, invites, splashes) and purchases make this especially important.

The options in the product spec are to block sign-up under 13, to offer a parent-managed kids mode without open invites or purchases, or to build a parental consent flow. This section will describe whichever approach is chosen. Until then, it intentionally states no policy.

This website

gulp.astelapps.com uses no cookies, no analytics and no third-party scripts, and the fonts are served from our own site. Cloudflare, which hosts it, processes basic request information such as IP addresses to deliver pages and protect against abuse.

Changes and contact

If we change this policy in a way that matters, we'll tell you in the app before the change takes effect. Questions are always welcome at privacy@astelapps.com.